Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
In reassessment proceedings, service of notice under s. 143(2) is a jurisdictional precondition, even where the return is filed beyond the time stipulated in the s. 148 notice, since such return is to be treated as a return under s. 139. Non-service of s. 143(2) is a fatal defect and is not curable under s. 292BB. The matter was remanded to the AO to verify whether s. 143(2) was served on or before completion of assessment; if not served, the reassessment is to be treated as null and void. Appeal partly allowed for statistical purposes. - ITAT
In reassessment proceedings, service of notice under s. 143(2) is a jurisdictional precondition, even where the return is filed beyond the time stipulated in the s. 148 notice, since such return is to be treated as a return under s. 139. Non-service of s. 143(2) is a fatal defect and is not curable under s. 292BB. The matter was remanded to the AO to verify whether s. 143(2) was served on or before completion of assessment; if not served, the reassessment is to be treated as null and void. Appeal partly allowed for statistical purposes. - ITAT
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